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Grecian Magnesite Mining v. Commissioner: Foreign Investor Not Subject to US Tax on Sale of Partnership Interest
  • McDermott Will & Emery
  • USA
  • August 11 2017

On July 13, 2017, the US Tax Court (TC) issued its opinion in Grecian Magnesite Mining v. Commissioner, 149 TC 3, holding that a foreign corporation


Section 338(h)(10) Election - S Corporation Stock Sale Treated as Asset Sale
  • Dickinson Wright
  • USA
  • August 7 2017

Generally, a buyer in a stock sale does not obtain a step-up (or down) in the basis of the acquired corporation’s assets, unlike in an


Sale of U.S. Operating Partnerships by Non-U.S. Persons May Not Generate ECIU.S. Tax Court Declines to Follow Revenue Ruling 91-32
  • K&L Gates
  • USA
  • August 4 2017

In a recently published decision, the U.S. Tax Court declined to follow the longstanding position of the U.S. Internal Revenue Service (“IRS”


Angel Investing on the Rise: Legal Considerations for the Formation of an Angel Fund
  • Thompson Hine LLP
  • USA
  • July 27 2017

Investors are becoming increasingly interested in the opportunities and benefits of launching angel funds. With a growing community of startup


U.S. tax changes loom large over cross-border deals
  • Osler Hoskin & Harcourt LLP
  • Canada, USA
  • July 26 2017

While the rollercoaster effort to repeal and replace Obamacare has claimed most of the attention in Washington over the past several weeks, there


ALJ Forces Combination of Hedge Fund Group in New York City
  • Pepper Hamilton LLP
  • USA
  • July 26 2017

On April 27, the New York City Tax Appeals Tribunal issued a decision requiring the related members of a hedge fund group to file a combined return


U.S. Tax Court Bounces Rev. Rul. 91-32: Sales of Partnership Interests by Foreign Partners May Not be Subject to U.S. Tax
  • Dickinson Wright
  • USA
  • July 25 2017

The practice of tax law is an exercise of statutory interpretation. A recent opinion of the U.S. Tax Court, Grecian Magnesite Mining, Indust. & Ship


Welcome News for Non-U.S. Persons Investing into U.S. Businesses: U.S. Tax Court Rejects Long-Standing IRS Ruling
  • Greenberg Traurig LLP
  • USA
  • July 25 2017

On July 13, 2017, the U.S. Tax Court, in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner,1 rejected the long-standing Internal


Partnerships Prepare for New Audit Regime
  • Cole Schotz PC
  • USA
  • July 24 2017

On November 2, 2015, new partnership audit rules, repealing existing TEFRA rules, were enacted in Section 1101 of the Bipartisan Budget Act (“BBA”


Foreign Partner Not Taxable on Partnership Sale
  • Pepper Hamilton LLP
  • USA
  • July 21 2017

Private equity and venture capital funds often invest in portfolio companies that are formed as partnerships or limited liability companies. But